CPO, CFTC, Investment Adviser

2020 Annual Compliance Obligation Reminders

Vedder Price on 2/11/2020

Investment advisers registered with the U.S. Securities and Exchange Commission (SEC) or with a state, as well as commodity pool operators and commodity trading advisors registered with the U.S. Commodity Futures Trading...more

CFTC Proposes to Streamline CPO and CTA Regulations by Codifying Prior Relief

Proskauer Rose LLP on 10/24/2018

On October 9, 2018, the Commodity Futures Trading Commission (CFTC) proposed new rules in connection with the CFTC's Project KISS Initiative directed at simplifying Commodity Pool Operator (CPO) and Commodity Trading Advisor...more

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Funds

Dechert LLP on 1/24/2018

The U.S. federal securities laws and the rules of U.S. self regulatory organizations (such as the Financial Industry Regulatory Authority) impose certain reporting and compliance obligations on investment advisers and funds....more

Investment Management Legal + Regulatory Update -- September 2014

Morrison & Foerster LLP on 9/17/2014

In This Issue: - Regulation: Long-Awaited Money Market Fund Rules Adopted - SEC Staff Offers Guidance Regarding Investment Advisers and Proxy Advisory Firms - SEC Staff Closes Loophole on BDC Asset...more

U.S. House Votes to Reauthorize the CFTC and Exclude Most RICs from CPO and CTA Requirements

Broker-Dealer Compliance + Regulation on 6/30/2014

The U.S. House of Representatives on June 24, 2014, passed a version of the CFTC reauthorization bill, H.R. 4413, that would exclude investment advisers to registered investment companies (RICs) from the definitions of...more

Year-End CFTC Reporting Requirements for Fund Advisers

Broker-Dealer Compliance + Regulation on 12/12/2013

The National Futures Association (NFA) reminded fund advisers claiming an exemption from registering as a commodity pool operator (CPO) that they must confirm by March 3, 2014 that will continue to rely on the exemption....more

CFTC Adopts Harmonization Rules for Investment Advisers that are Commodity Pool Operators of Registered Funds

K&L Gates LLP on 8/28/2013

On August 13, 2013, the Commodity Futures Trading Commission (“CFTC”) adopted long-awaited harmonization rules (“Harmonization Rules”) for operators of registered investment companies (“Registered Funds”) that are subject to...more

Legal Alert: CFTC Issues Highly Anticipated Harmonization Rules

Eversheds Sutherland (US) LLP on 8/14/2013

Today, the Commodity Futures Trading Commission (CFTC) provided long-awaited clarification and relief to investment advisers that are registered with the CFTC as commodity pool operators (CPOs) and/or commodity trading...more

Impact of the SEC and CFTC Issuing Final Identity Theft “Red Flag” Rules

K&L Gates LLP on 7/2/2013

On April 19, 2013, the Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (“CFTC” and, together with the SEC, the “Commissions”) published final rules (“Red Flag Rules”) in the Federal...more

Amendments to CFTC Rule 4.5 Affecting Advisers to Registered Investment Companies Upheld

Eversheds Sutherland (US) LLP on 6/28/2013

On Tuesday, June 25, 2013, a three-judge panel of the United States Court of Appeals for the District of Columbia Circuit (Court of Appeals) affirmed the decision of the United States District Court for the District of...more

DC Court of Appeals Upholds Amendments to CFTC Rule 4.5 Affecting Advisers to Registered Investment Companies

Eversheds Sutherland (US) LLP on 6/27/2013

On Tuesday, June 25, 2013, a three-judge panel of the United States Court of Appeals for the District of Columbia Circuit (Court of Appeals) affirmed the decision of the United States District Court for the District of...more

SEC and CFTC Issue Identity Theft Red Flags Rules Applicable to Financial Institutions and Creditors

Dechert LLP on 4/30/2013

The SEC and CFTC recently issued joint Identity Theft Red Flags Rules (the “Rules”), which are rules and guidelines requiring certain financial institutions worldwide to adopt comprehensive data security programs to detect...more

The SEC and CFTC Adopt Identity Theft Red Flag Rules

Proskauer on Privacy on 4/24/2013

The Securities and Exchange Commission (the “SEC”) and Commodity Futures Trading Commission (the “CFTC”) recently adopted rules requiring entities subject to their respective enforcement authorities to adopt and implement...more

NFA Provides Bylaw 1101 Guidance to Commodity Pool Operators of Investment Companies

Katten Muchin Rosenman LLP on 12/29/2012

Under amended Commodity Futures Trading Commission Regulation 4.5, registered investment advisers (RIAs) to registered investment companies engaging in more than minimal commodity trading activities will be required to...more

U.S. District Court Rebuffs ICI Challenge To CFTC Rule 4.5 Amendments

Troutman Pepper on 12/14/2012

On December 12, 2012, the U.S. District Court for the District of Columbia released its decision in Investment Company Institute v. U.S. Commodity Futures Trading Commission, rebuffing the Investment Company Institute (ICI)’s...more

Commodity Pool Operator › Commodities Futures Trading Commission › Investment Adviser

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